Home Depot U.S.A., Inc. v. United States, No. 18-1206 (Fed. Cir. 2019)Annotate this Case
Doorknobs with integral locks, imported by Home Depot, were classified by U.S. Customs and Border Protection as locks under the Harmonized Tariff Schedule of the United States (HTSUS) heading 8301. Home Depot argued that the products should have been classified under HTSUS heading 8302 as metal fittings for doors, including metal doorknobs. The International Trade Court affirmed. The Federal Circuit vacated, holding that the products are properly classified as composite goods within the meaning of HTSUS General Rule of Interpretation 3(b). The court remanded to the Trade Court to make a finding as to the “essential nature” of the composite goods, as directed by GRI 3(b), in order to determine under which of the two competing headings the goods should be classified. The two headings “each refer to part only” of the materials in the composite goods, and, according to GRI 3(a), the competing headings must be regarded as equally specific.